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Indicator 3.2.4
by Contact on 8 October 2026
Requirement
The UoC shall ensure that original identity documents are not retained, including by any recruitment agencies used. If a secure storage option for identity documents is provided, the UoC shall ensure that: a) it is the choice of the employee to use the storage, and; b) stored items are logged, and; c) employees have free access to the storage.
How Do I Interpret This Requirement?
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The retention of identity documents is a violation of employees’ basic rights.
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When employees cannot easily prove their identity or citizenship status or have the documents required to travel, they become more vulnerable to exploitation.
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Employees should always either possess or have access at any time to their original personal documentation, including documentation needed to terminate employment, and to leave the country and travel freely. For example:
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ID cards
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passports
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visas
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If a recruitment agency is involved and stores employees’ personal documentation there, it is still the responsibility of the UoC to ensure that the conditions outlined in the indicator are met.
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Evidence of Implementation
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storage solutions for personal documents
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policies about the retention of employee documents.
Auditors Should Confirm
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whether or not employees store personal documents anywhere at the UoC;
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that employees are not asked to hand over any personal documents.